2021.06.24

2020 (Gyo-Hi) 103

Minshu Vol. 75, No. 7

Judgment concerning the issue of whether, in the case where a judgment was rendered to rescind the part of a disposition of increased reassessment made after the filing of a return under Article 55 of the Inheritance Tax Act (prior to amendment by Act No. 10 of 2006; the same applies hereinafter) that exceeded the amount of tax pertaining to the aforementioned return and the judgment became final and binding, the taxation agency, when making a disposition in response to a request for reassessment under the provisions of Article 32, item (i) of the Inheritance Tax Act and a reassessment under the provisions of Article 35, paragraph (3), item (i) of the same Act after the passage of the period of exclusion for reassessment prescribed in the Act on General Rules for National Taxes, assumes the obligation to calculate the amount of tax, etc. by using the values, etc. of individual properties indicated in the judgment due to the binding effect of the judgment

Case seeking rescission of a disposition of reassessment of inheritance tax, etc.

Judgment of the First Petty Bench, quashed and decided by the Supreme Court

Tokyo High Court, Judgment of December 4, 2019

Where the court found the values of individual properties that differ from those indicated in a return filed under Article 55 of the Inheritance Tax Act (prior to amendment by Act No. 10 of 2006; the same applies hereinafter) in an action for the rescission of a disposition of increased reassessment filed after the filing of the aforementioned return and rendered a judgment to rescind the part of the disposition exceeding the amount of tax pertaining to the aforementioned return on the grounds that the amount of tax calculated fell below the amount of tax pertaining to the aforementioned return as a result of said finding of the values and the judgment became final and finding, the taxation agency: when making a disposition in response to a request for reassessment under the provisions of Article 32, item (i) of the Inheritance Tax Act and a reassessment under the provisions of Article 35, paragraph (3), item (i) of the same Act after the passage of the period of exclusion for reassessment prescribed in the Act on General Rules for National Taxes, should never assume the obligation to calculate the amount of tax, etc. by using the values and valuation methods of individual properties indicated in the judgment due to the binding effect of the judgment.

Article 32, item (i) and Article 35, paragraph (3), item (i) of the Inheritance Tax Act (prior to amendment by Act No. 10 of 2006), Article 55 of the Inheritance Tax Act (prior to amendment by Act No. 114 of 2011), and Article 33, paragraph (1) of the Administrative Case Litigation Act

Inheritance Tax Act (prior to amendment by Act No. 10 of 2006)
(Special Provisions on Request for Reassessment)
Article 32 (1) If the assessed value and the amount of inheritance tax or gift tax pertaining to a return or determination in relation to inheritance tax or gift tax (if an amended return was filed or a reassessment was made after the submission of the return or the receipt of the determination, the assessed value and the amount of inheritance tax or gift tax pertaining to that amended return or reassessment) becomes excessive due to a circumstance that falls under any of the following items, a person who filed the return or received the determination may request that the district director of the tax office having jurisdiction over the place of tax payment reassess the assessed value and the amount of inheritance tax or gift tax under the provisions of Article 23, paragraph (1) (Request for Reassessment) of the Act on General Rules for National Taxes only within four months from the day following the date on which the person acquired knowledge of occurrence of any of the circumstances provided in the following items:
(i) in the case where the assessed value of property that has not been divided pursuant to the provisions of Article 55 was calculated in accordance with the share in inheritance or portion of comprehensive testamentary gift under the provisions of the Civil Code (excluding Article 904-2 (Contributory Portion)), the property is divided thereafter and the assessed value pertaining to the property acquired by a coheir or testamentary donee by a universal succession through the division becomes different from the assessed value calculated in accordance with the share in inheritance or portion of comprehensive testamentary gift;

(Special Provisions on Reassessment and Determination)
Article 35
(3) Where the district director of a tax office made a reassessment based on a request for reassessment under the provisions of Article 32, paragraph (1), items (i) to (v), if either of the following circumstances exists in relation to another person who acquired property from the decedent of the person who filed the request through succession or testamentary gift (including a person who acquired property to which the provisions of Article 21-9, paragraph (3) are applicable from the decedent through gift; hereinafter the same applies in this paragraph), the district director of the tax office is to make the reassessment or determination of the assessed value or the amount of inheritance tax pertaining to that person based on the circumstance; provided, however, that this does not apply after the day on which one year has passed from the date of the request or the day on which it becomes impossible to make a reassessment or determination pursuant to the provisions of Article 70 of the Act on General Rules for National Taxes, whichever comes later:
(i) in the case where the other person is a person who filed a return under the provisions of Article 27 or 29 (including a return filed after the due date and an amended return pertaining to such return) or received a determination concerning inheritance tax, if the assessed value or the amount of inheritance tax pertaining to the return or determination (if an amended return is filed or a reassessment is made after the return or determination, the assessed value or the amount of inheritance tax pertaining to the amended return or reassessment) becomes different from the assessed value or the amount of inheritance tax pertaining to that other person that is calculated based on a fact that caused the reassessment based on the request;

Inheritance Tax Act (prior to amendment by Act No. 114 of 2011)
(Taxation on Undivided Estate)
Article 55 In the case of filing a return in relation to inheritance tax pertaining to property acquired through succession or comprehensive testamentary or of making a reassessment or determination in relation to inheritance tax pertaining to the property, if the whole or part of the property acquired through succession or comprehensive testamentary has not been divided by coheirs or testamentary donees by a universal succession, the assessed value of the undivided property is to be calculated by considering that each of the coheirs or testamentary donees by a universal succession acquired the property in accordance of the share in inheritance or portion of comprehensive testamentary gift under the provisions of the Civil Code (excluding Article 904-2 (Contributory Portion)); provided, however, that if the property is subsequently divided and the assessed value of the property that each of the coheirs or testamentary donees by a universal succession acquired through the division becomes different from the assessed value calculated in accordance with the share in inheritance or portion of comprehensive testamentary gift, the taxpayer is not to be precluded from filing a return or filing a request for reassessment provided in Article 32, paragraph (1), and the district director of a relevant tax office is not precluded from making a reassessment or determination.

Administrative Case Litigation Act
Article 33　(1)　A judgment to revoke an original administrative disposition or administrative determination is binding on the administrative authority that has made the original administrative disposition or administrative determination and any other relevant administrative authority with regard to the case.

1. The judgment in prior instance is modified as follows.

Of the judgment in first instance, the part against the appellant of final appeal is revoked, and in relation to the same part, the claim of the appellee of final appeal is dismissed with prejudice on the merits.

Of the judgment in first instance, the appeal filed by the appellant in relation to the part dismissing without prejudice the action filed by the appellee is dismissed with prejudice on the merits.

The incidental appeal filed by the appellee is dismissed with prejudice on the merits.

2. The total court costs shall be borne by the appellee.

Concerning the reasons for a petition for acceptance of final appeal stated by the counsel for final appeal, KIYONO Masahiko, et al.

1. The outline of facts lawfully determined by the court of prior instance is as follows.

(1) On December 27, 2004, the appellee filed a return in relation to inheritance tax pertaining to succession that was commenced due to the death of the appellee's mother on February 28, 2004 (hereinafter referred to as the "Succession") with the appellee's six siblings, who were coheirs, (hereinafter this return is referred to as the "Return"). In the Return, the assessed value was calculated by considering that the property was acquired by the coheirs in accordance with their statutory shares in inheritance (one-seventh for each of the coheirs) pursuant to Article 55 of the Inheritance Tax Act (prior to amendment by Act No. 10 of 2006; the same applies hereinafter) because the division of estate had not been completed, and the appellee's assessed value was determined to be 2,263,744,000 yen and the amount of tax to be paid was determined to be 1,070,950,000 yen.

(2) On February 13, 2007, the District Director of the Kotohigashi Tax Office made a disposition of increased reassessment to the appellee on the grounds that the values of some of the shares stated in the "Brand" column in Appended Table 1 attached to the judgment in first instance (hereinafter referred to as the "Shares"), which were included in the estate pertaining to the Succession, were underassessed.

On January 21, 2009, the appellee filed, with the Tokyo District Court, an action to seek the rescission of the part of the aforementioned disposition of increased reassessment, which was partly rescinded by the Director of the Tokyo Regional Taxation Bureau upon objection of the appellee, wherein the amount of tax to be paid exceeded the amount of tax to be paid pertaining to the Return (1,070,950,000 yen). Incidentally, on February 28, 2011, the District Director of the Kotohigashi Tax Office made a disposition of reduced assessment to the appellee to further rescind part of the aforementioned disposition of increased reassessment, which was partly rescinded by the Director of the Tokyo Regional Taxation Bureau, while determining the assessed value to be 4,060,890,000 yen and the amount of tax to be paid to be 1,970,009,300 yen (hereinafter the aforementioned disposition of increased reassessment that was partly rescinded by this disposition of reduced reassessment is referred to as the "Previous Disposition of Reassessment").

(3) On March 2, 2012, the Tokyo District Court rendered a judgment to rescind the part of the Previous Disposition of Reassessment wherein the amount of tax to be paid exceeded the amount of tax to be paid pertaining to the Return. On February 28, 2013, the Tokyo High Court rendered a judgment to dismiss the appellee's appeal with prejudice on the merits, and the same judgment became final and binding (hereinafter this judgment is referred to as the "Previous Judgment").

The issues in the aforementioned action were the values of the shares of Company A (hereinafter referred to as "Company A's shares") and the shares of Company B (hereinafter referred to as "Company B's shares"), both of which are shares without market price, out of the Shares. Specifically, the issues were as follows: [i] regarding Company A's shares, whether Company A falls under the category of specified companies holding shares, which are to be exceptionally valued by the net asset value method, etc. on the premise that the company is a large company (the shares of a large company are, in principle, to be valued by the comparable similar business method) as mentioned in the Basic Circular Notice on Property Valuation (Direct Tax Department/Property Tax Division 56 and Direct Tax Department/Department of Ruling and Legal Affairs/Director of Property Valuation 17; Circular Notice of the Commissioner of the National Tax Agency of April 25, 1964; hereinafter referred to as the "Valuation Circular Notice"); and [ii] regarding Company B's shares, the value thereof in light of the value of Company A's shares held by Company B on the premise that Company B's shares are valued by the net asset value method. In the Previous Judgment, the court ruled that Company A's shares should be valued by the comparable similar business method, which is a valuation method to be used in principle, because some of the determination standards concerning specified companies holding shares in the Valuation Circular Notice are not recognized as reasonable, and on that premise, Company A is not found to fall under the category of specified companies holding shares. The court then found the value of Company A's shares and the value of Company B's shares to be 4,653 yen per share and 31,189 yen per share, respectively. These values (however, regarding Company B's shares, 19,132 yen per share, which is the value obtained by accurate calculation on the premise of the explanations made in the Previous Judgment) fell below not only the values in the Previous Disposition of Reassessment (regarding Company A's shares, 19,002 yen per share; regarding Company B's shares, 64,908 yen per share) but also the values in the Return (regarding Company A's shares, 11,185 yen per share; regarding Company B's shares, 21,009 yen per share). In addition, the court ruled that the parties agree to use the values in the Previous Disposition of Reassessment with regard to other shares out of the Shares and also determined the use of those values in the Previous Judgment. Consequently, the amount of tax to be paid by the appellee fell below the amount of tax pertaining to the Return. Therefore, the part of the Previous Disposition of Reassessment exceeding the amount of tax pertaining to the Return was rescinded.

(4) In response to the Previous Judgment, the Commissioner of the National Tax Agency partially amended the determination standards concerning specific companies holding shares in the Valuation Circular Notice and publicized the amended standards in May 2013.

(5) Regarding the case of petition for the division of estate pertaining to the Succession, conciliation (hereinafter referred to as the "Conciliation") was established at the Tokyo Family Court on January 16, 2014, and the appellee acquired six-sevenths of the Shares with respect to each brand.

(6) On February 21, 2014, two of the appellee's siblings filed a request for reassessment under the provisions of Article 32, item (i) of the Inheritance Tax Act on the grounds that the assessed value pertaining to property that they acquired through the establishment of conciliation differed from the assessed value pertaining to the Return. In response to the request, the District Director of the Kotohigashi Tax Office made a disposition of reduced reassessment with regard to each of the siblings on June 20, 2014.

(7) On May 16, 2014, the appellee filed a request for reassessment with the District Director of the Kotohigashi Tax Office under the provisions of Article 32, item (i) of the Inheritance Tax Act, while alleging the assessed value to be 960,805,000 yen and the amount of tax to be paid to be 441,990,400 yen on the grounds of the establishment of the Conciliation. On that occasion, the appellee calculated the amount of tax, etc. by considering that the values of the Shares are the same as those found in the Previous Judgment (however, regarding Company B's shares, 19,132 yen per share, as the value obtained by accurate calculation on the premise of the explanations in the Previous Judgment).

(8) On November 12, 2014, the District Director of the Kotohigashi Tax Office made a disposition of notification to the appellee to the following effect: there is no ground for reassessment (hereinafter referred to as the "Disposition of Notification") on the grounds that the part of the request for reassessment mentioned in (7) above requesting the reduction of the values of the shares is a request for the rectification of an error in the valuation of the values of the shares in the Return and does not fall under the circumstance provided in Article 32, item (i) of the Inheritance Tax Act. The District Director also determined that with the Dispositions of Reduced Reassessment mentioned in (6) above, the assessed value and the amount of inheritance tax pertaining to the Return filed by the appellee became different from the assessed value and the amount of inheritance tax calculated on the basis of the fact that the estate was divided by the Conciliation. Based on this determination, the District Director made a disposition of increased reassessment that determined the assessed value to be 4,904,109,000 yen and the amount of tax to be paid to be 2,325,671,800 yen (hereinafter this disposition is referred to as the "Disposition of Reassessment," and the same disposition and the Disposition of Notification are collectively referred to as the "Disposition of Reassessment, etc.") under Article 35, paragraph (3), item (i) of the same Act. In the Disposition of Reassessment, etc., the amount of tax, etc. was calculated by considering the values of the Shares to be the same as those in the Return.

2. In this case, the appellee demands that the appellant rescind the parts of the Disposition of Reassessment, etc. wherein the amount of tax to be paid exceeded 446,899,300 yen, respectively. What is disputed in this case is the legitimacy of the Disposition of Reassessment, etc. wherein the amount of tax, etc. was calculated by using the values of the Shares in the Return.

3. The court of prior instance determined as summarized below based on the aforementioned facts, and upheld the claim pertaining to the Disposition of Notification and the claim for the rescission of the part of the Disposition of Reassessment that exceeded the amount of tax to be paid pertaining to the Return.

In the Previous Judgment, the court determined the methods of valuation of Company A's shares and Company B's shares out of the Shares that fall under estate, and calculated the assessed value and the amount of tax to be paid based on the values of the Shares calculated by using the same methods, etc. Consequently, the court elicited a determination that the part of the Previous Disposition of Reassessment that exceeded the amount of tax to be paid pertaining to the Return is illegal. Therefore, the determination concerning the methods of valuation of the Shares or the values thereof in the Previous Judgment has come to have the binding effect prescribed in Article 33, paragraph (1) of the Administrative Case Litigation Act. Therefore, when making a disposition in relation to a request for reassessment under the provisions of Article 32, item (i) of the Inheritance Tax Act and a reassessment under the provisions of Article 35, paragraph (3), item (i) of the same Act, the taxation agency must calculate the assessed value and the amount of tax to be paid after the division of estate based on the methods of valuation of the Shares or the values thereof in the Previous Judgment.

4. However, the aforementioned determination of the court of prior instance cannot be upheld for the following reasons.

(1) The amount of inheritance tax pertaining to each heir, etc. is to be calculated by [i] first calculating the total amount of inheritance tax, which is the total sum of the amounts calculated by multiplying each of the acquired amounts in the case where the amount obtained by deducting the amount of basic personal exemption from the total sum of the amounts equivalent to the assessed values of inheritance taxes pertaining to all persons who acquired property from the same decedent through succession or gift (the total sum of the values of property that those persons acquired through the succession, etc.) by the prescribed tax rate (Article 16 of the Inheritance Tax) and [ii] then multiplying the calculated amount by the proportion of the assessed value pertaining to each of the heirs, etc. to the total sum of the assessed values pertaining to all persons who acquired the property (hereinafter referred to as the "Proportion of Acquisition") (Article 17 of the same Act).

The Inheritance Tax Act provides that a person must file an inheritance tax return within 10 months from the day following the date on which the person acquired knowledge of commencement of succession (Article 27, paragraph (1) of the same Act). The same Act provides that if the whole or part of estate has yet to be divided, a return is to be filed by calculating the assessed value of property that has yet to be divided while considering that each coheir or testamentary donee by a universal succession has acquired the property in accordance with his/her share in inheritance or portion of comprehensive testamentary gift (Article 55 of the same Act), from the perspective of preventing delay in taxation. However, the Inheritance Tax Act also provides that if the assessed value and the amount of inheritance tax pertaining to the aforementioned return become excessive due to the circumstance where the property was subsequently divided and the assessed value pertaining to the property acquired through the division became different from the assessed value calculated in accordance with the share in inheritance, etc. under the provisions of Civil Code, the person who filed the aforementioned return may file a request for reassessment only within four months from the day following the date on which the person acquired knowledge of occurrence of the circumstance (Article 32, item (i) of the same Act). Furthermore, the Inheritance Tax Act provides as follows: in the case where the district director of a tax office made a reassessment based on a request for reassessment under the provisions of the same item, etc., if there is a circumstance where the assessed value or the amount of inheritance tax pertaining to a return filed by another person who acquired property from the decedent of the person who filed the request through succession, etc. becomes different from the assessed value or the amount of inheritance tax pertaining to that other person that is calculated based on a fact that caused the reassessment based on the request, the district director of the tax office reassesses the assessed value or the amount of inheritance tax pertaining to that other person based on the circumstance; however, the district director of the tax office may not make such reassessment after the day on which one year has passed from the date of the request or the day on which it becomes impossible to make a reassessment pursuant to the provisions of Article 70 of the Act on General Rules for National Taxes, whichever comes later (Article 35, paragraph (3), item (i) of the Inheritance Tax Act).

(2) Article 32, item (i) and Article 35, paragraph (3), item (i) of the Inheritance Tax Act thus provide as follows: in the case where a subsequent circumstance peculiar to inheritance tax, specifically, a change of property acquired by each heir as a result of the division of estate after the filing of a return under Article 55 of the same Act, occurred, a heir, etc. may file a request for reassessment on the grounds that the amount of inheritance tax, etc. pertaining to the aforementioned return became excessive due to the aforementioned subsequent circumstance, and if a reassessment was made based on the request, the district director of a tax office may make a reassessment to the extent of the changes of the amounts of inheritance tax, etc. of other heirs due to the aforementioned subsequent circumstance, only within a certain period of time after the division of estate, irrespective of the time limit prescribed in the Act on General Rules for National Taxes, as special provisions on Article 23, paragraph (1) and Article 24 of the same Act, which provide for request for reassessment and reassessment. The purport of these provisions is considered to exist in establishing a special procedure wherein the amount of inheritance tax once calculated and determined in accordance with the statutory share in inheritance, etc. based on a return under Article 55 of the Inheritance Tax Act is to be readjusted in accordance with the result of the division of estate that was actually conducted, thereby ensuring fair tax burden among heirs.

For the reasons described above, it is impossible to argue any circumstance other than the aforementioned subsequent circumstance in a request for reassessment under the provisions of Article 32, item (i) of the Inheritance Tax Act. Therefore, it is impossible to use an error in the valuation of the values of individual properties that served as the basis for the calculation of the amount of inheritance tax that had been determined once as mentioned above as a ground for filing the request for reassessment. It is also reasonable to consider that the taxation agency cannot rectify the aforementioned error in valuation in a disposition to be made in response to the request after the passage of the period of exclusion for reassessment prescribed in the Act on General Rules for National Taxes. In addition, the taxation agency also cannot rectify the aforementioned error in valuation even in a reassessment under the provisions of Article 35, paragraph (3), item (i) of the Inheritance Tax Act, and it is reasonable to consider that the taxation agency is to use the aforementioned value that served as the basis for the calculation of the amount of inheritance tax that had been once determined.

(3) If a judgment rescinding a disposition becomes final and binding, the administrative authority, etc. that made the disposition is to assume the obligation to take action in accordance with the findings and legal determinations that are necessary to draw the main text of the judgment regarding the case due to the binding effect of the judgment (Article 33, paragraph (1) of the Administrative Case Litigation Act). However, even by the aforementioned binding effect, the administrative authority is not obliged to take action that lacks a statutory ground. Therefore, the content of said obligation is considered to be limited to the action for which the administrative authority has the statutory authority.

In the case where, in an action for the rescission of a disposition of increased reassessment that was made after the filing of a return under Article 55 of the Inheritance Tax Act, the court found the values of individual properties that differ from those in the aforementioned return and rendered a judgment to rescind the part of the disposition exceeding the amount of tax pertaining to the aforementioned return on the grounds that the amount of tax calculated as a result of the finding of the values fell below the amount of tax pertaining to the return and the judgment became final and binding, as long as the amount of tax after the rescission, by that judgment, of part of the disposition of increased reassessment was calculated based on the values of individual properties in the aforementioned return, the taxation agency must be considered not to have the statutory authority to make a disposition in response to a request for reassessment under the provisions of Article 32, item (i) of the Inheritance Tax Act and a reassessment under the provisions of Article 35, paragraph (3), item (i) of the same Act by using the values and valuation methods indicated in the judgment after the passage of the period of exclusion for reassessment prescribed in the Act on General Rules for National Taxes, in light of the determination mentioned in (2) above.

Consequently, it should be said that, in the aforementioned case, when making a disposition in response to a request for reassessment under the provisions of Article 32, item (i) of the Inheritance Tax Act and a reassessment under the provisions of Article 35, paragraph (3), item (i) of the same Act after the passage of the period of exclusion for reassessment prescribed in the Act on General Rules for National Taxes, the taxation agency should never assume the obligation to calculate the amount of tax, etc. by using the values and valuation methods of individual properties indicated in the judgment due to the binding effect of the judgment, without the need to discuss whether the part determining the values and valuation methods of individual properties in the judgment comes to have the binding effect.

(4) According to the explanations made above, in this case wherein the period of exclusion for reassessment prescribed in the Act on General Rules for National Taxes (prior to amendment by Act No. 114 of 2011) had already passed at the time of the Disposition of Reassessment, the District Director of the Kotohigashi Tax Office cannot be considered to be required to calculate the amount of tax, etc. by using the values and valuation methods of the Shares indicated in the Previous Judgment when making the Disposition of Reassessment, but the District Director is to calculate the assessed value and the amount of inheritance tax based on the values of the Shares in the Return. Therefore, the Disposition of Reassessment is lawful. Incidentally, the appellee also argues that even if the values of the Shares in the Return are used in the calculation of the total amount of inheritance tax, the values indicated in the Previous Judgment should be used in calculating the portion of acquisition of each heir. However, the aforementioned argument is groundless, taking into account the fact that the Inheritance Tax Act provides that the portion of acquisition of each heir is to be calculated based on the assessed value in the same manner as that used for the calculation of the total amount of inheritance tax, as mentioned in (1) above.

5. The determination of the court of prior instance that differs from the above contains a violation of laws and regulations that has clearly influenced the judgment, and the counsel's arguments are well-grounded as arguments to this effect.

Moreover, both a disposition of notification to the effect that there is no ground for reassessment, which was made in response to a request for reassessment under the provisions of Article 32, item (i) of the Inheritance Tax Act that was filed by a specific heir in the case where the division of estate was conducted after the filing of a return under Article 55 of the same Act and an increased reassessment under the provisions of Article 35, paragraph (3), item (i) of the same Act in relation to the heir are dispositions that were made in relation to the same heir based on a subsequent circumstance peculiar to inheritance tax, specifically, a change of property acquired by each heir due to the division of estate, as mentioned in 4.(2) above. The aforementioned increased reassessment is a disposition that determines the amount of tax by increasing the amount once determined on the grounds that the division of estate was conducted. Therefore, the aforementioned increased reassessment can be considered to substantially include the content of the aforementioned disposition of notification to the effect that there is no ground for reducing the amount of tax in association with the division of estate. In addition, it is also considered that the heir, who has filed the aforementioned request for reassessment, can demand the rescission of the part exceeding the amount of tax pertaining to the aforementioned request for reassessment in an action for the rescission of the aforementioned increased reassessment. Therefore, there is no benefit of seeking the rescission of the Disposition of Notification, and the part seeking the rescission of the Disposition of Notification in this action is thus unlawful and should be dismissed without prejudice.

Therefore, of the judgment in prior instance, the part against the appellant should inevitably be quashed, and according to the explanations made above, the judgment in prior instance is modified as stated in paragraph 1 of the main text.

Accordingly, the Court unanimously decides as set forth in the main text of the judgment.

Justice MIYAMA Takuya

Justice IKEGAMI Masayuki

Justice KOIKE Hiroshi

Justice KIZAWA Katsuyuki

Justice YAMAGUCHI Atsushi